Baltikums Bank and Privatbank each have been fined EUR 35,575 and told to draw up action plans that would be enable them to identify transactions that are aimed at circumventing or breaching of the international sanctions in the future.

Although market interest should be required and paid on related party loans, under the current regulations, a below-market interest rate on an employee loan will not be a binding agreement and will not be a governing provision, unless entered into with a principal purpose of circumventing the SCOS requirement.

When the administration tells students that drinking is not permitted, the cadets hear from upperclassmen that there is a long tradition of delicately circumventing this particular rule; when the administration tells students that sexual assault is unacceptable, they hear from juniors and seniors that having sex with passed-out girls is actually okay.

The company's employee business expense reimbursement policy will not include any provisions that could have a principal purpose of circumventing the one-class-of-stock requirement (in particular, the policy will not alter the distribution and liquidation rights given to the outstanding stock by the corporation's governing provisions).

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